AAFP Proposes Revised Meaningful Use Stage Two Compliance Timeline

The AAFP recently made an urgent appeal to CMS to modify its aggressive meaningful use (MU) stage two timeline that, if left intact, could "outstrip the capacity of many certified electronic health record technology (CEHRT) vendors and ambulatory family medicine practices."

In an Aug. 7 letter to CMS Administrator Marilyn Tavenner, M.S., AAFP Board Chair Glen Stream, M.D., M.B.I., of Spokane, Wash., said that although the AAFP supports family physicians' adoption of EHRs and the patient-centered medical home model of care, Academy leaders increasingly are concerned about both the regulatory expectations of MU stage two and the timeframe for physician compliance.

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The AAFP is concerned that certified electronic health record vendors and a good many family physicians aren't prepared to comply with CMS' aggressive timeline for meaningful use stage two compliance.

The Academy recently proposed a plan that would extend the timeline for compliance with meaningful use stage two requirements by 12 months.

The proposal would create three distinct groups of attesting physicians, and each group would be affected differently by the timeline modification.

He highlighted the AAFP's main concern with current implementation deadlines set by CMS and the Office of the National Coordinator for Health IT. "Our members will be unable to obtain the products, implementation services training and support required to meaningfully use 2014 CEHRT in their practices while continuing to provide the high levels of safety, quality and service that their patients deserve.

"Though we do not wish to impede the progress of early adopter physicians poised for MU stage two on Jan. 1, 2014, we do not wish to see other family physicians who have committed to health care transformation through the thoughtful application of health IT abandon the MU journey due to factors beyond their control," said Stream.

He presented an AAFP proposal that would advance the priorities of MU while at the same time maintaining the current momentum of health care transformation.

"We urge CMS not to delay the implementation of MU stage two but to extend the timeframe for compliance with MU stage two requirements by 12 months," said Stream.

The AAFP proposal would create three distinct cohorts of physicians and other eligible professionals, each of which would be affected differently by the modified schedule. In his letter, Stream outlined the requirements for each of the three groups in detail, but a brief overview of each group's requirements shows that

cohort one would include physicians who attest to MU in 2014 as their first payment year and who then would follow a specific timeline for MU reporting to receive a bonus payment;

cohort two would include physicians attesting to MU in 2014 as their second payment year, and they would follow a separate set of EHR upgrade and reporting period guidelines to receive a 2015 bonus payment; and

cohort three would include physicians attesting to MU in 2014 as their third or fourth payment year. This group also would have to comply with specific EHR upgrade and reporting period guidelines, and qualifying physicians would receive both their 2014 and 2015 MU bonus payments.

"This modified timeline would allow exemplar practices to implement MU stage two requirements early in 2014," said Stream. As an added benefit, the experiences of that first group of practices could be leveraged by physicians in the next two groups, as well as by EHR vendors.

"Pressure would be kept on vendors to be ready for MU stage two by Jan. 1, 2014, while distributing the strain of conversion of vendor product and physician workflow over a 21-month period rather than a nine-month period," said Stream.

The AAFP letter includes a four-color illustration to show how the Academy's MU stage two extension proposal would meter 2014 CEHRT upgrade demand.